The commission voted in July to investigate whether Patricia McCaig, in her role as an adviser on the bridge project, should have filed disclosure reports with the commission, registered as a lobbyist or if her role represented a conflict of interest.

In a 41-page report to the commission obtained by The Oregonian on Friday, investigator Deborah Tuss wrote that the commission should drop the complaint.

“There appears to be insufficient evidence to infer that Ms. McCaig violated Oregon government ethics law or Oregon lobbying regulation law as alleged,” Tuss wrote. “It is recommended the Oregon Government Ethics Commission dismiss this complaint.”

The commission will meet Feb. 14 to decide whether to dismiss or advance the complaint.

McCaig declined to comment on the investigation Friday. In July, she told The Oregonian that she looked forward to the conclusion of the case.

The investigation examined three allegations raised in two complaints filed last year.

Did McCaig violate the law by not registering as a lobbyist? The investigation found there was “insufficient basis” to demonstrate McCaig spent more than 24 hours lobbying in a given three-month period, the threshold for registering as a lobbyist under Oregon law.

Did McCaig’s role as an adviser to Gov. John Kitzhaber on the CRC require her to file a disclosure report? Oregon law requires “any assistant in the governor’s office other than personal secretaries and clerical personnel” to file an annual financial disclosure report. But the investigation found that McCaig didn’t work in the governor’s office. She instead worked for the two-state CRC project, overseen by the Oregon and Washington Departments of Transportation.

Did payments to McCaig from David Evans and Associates constitute a conflict of interest? The investigation found that while David Evans and Associates cut checks for McCaig, the contractor did so at the behest of the state agencies that directed the project, acting as a pass-through entity.